SecProbe.io

May 3, 2011
 Ralph Montrone Chief Executive Officer Trail One, Inc.
1844 South 3850 West
Salt Lake City, UT 84104
Re: Trail One, Inc.
Amendment No. 3 to Registrati on Statement on Form S-1
Filed on April 19, 2011
  File No. 333-170781

Dear Mr. Montrone:

We have reviewed your responses to the comments in our letter dated March 30, 2011
and have the following additional comments.
 General

1. Please revise your table of contents to include the Descrip tion of Property and
Independent Director/Corporate Governance Committee sections.
 Registration Statement Cover Page

2. Please remove the “small business issuer” de signation on the cover of the registration
statement.

Calculation of Registration Fee Table

3. We note your response to our prior comment th ree and reissue our co mment.  It appears
that you are determining the registration fee pur suant to Rule 457(a) as opposed to Rule
457(o).  Please advise or revi se your fee table accordingly.
 Prospectus Cover Page

4. We note your disclosure in the last sentence on the prospectus cover page.  Please advise
as to what supplements you may have to the prospectus.  Alternatively, please delete the
reference to any supplemen ts to the prospectus.

Ralph Montrone Trail One, Inc. May 3, 2011 Page 2

Prospectus Summary, page 1

 General Introduction, page 1

5. Please revise the first paragraph of this se ction to update your lo sses from inception to
December 31, 2010.

6. We note your response to our prio r comment four and reissue our  comment in part.  It is
still unclear from your disclosure how you intend  to market individualized license tags to
the wholesale market.  Please clarify what pr oduct will actually be so ld to the wholesale
customers.

7. Please revise to explain why there is a signi ficant price range of $80 to $700 per tag at
which you plan to sell your products to wholesal ers.  Please also advise as to how this
disclosure regarding the price range is consis tent with the disclosure in the last full
paragraph on page 16 regarding a selling price of $150.

8. Although we note your response to our prior co mment six, please revise your registration
statement throughout to disclose consistently  your plans to raise capital through equity
security sales, debt instruments, and privat e financing.  In this regard we note, for
example, your disclosure on pages 15, 17, 22, 23, 25, and 27.
 Risk Factors, page 3

9. We note your response to our prior comment nine .  Please advise as to why it is only the
risks described on page ten of the prospectus that, if realized, could harm your business,
operating results and financial condition.  Altern atively, please revise your disclosure to
clarify that all risks described in the Ri sk Factors section beginning on page 6 could
impact your business, operating re sults and financial condition.
 Risk Factors, page 6

We Require Additional Capital Which We May Be Unable To Raise, page 6

10. We note your response to our prior comment ten and reissue in part.  Please clarify where
you accounted for the cost of $10,000 for deve lopment of strategic relationships
described on page 23.

11. We note your response to our prior comment  11.  Please advise as to how the new
estimated cost to register the shares of common stock of $40,000 is consistent with your
estimated monthly burn rate of  $2,500, especially in light of  the fact that you anticipate
$15,000 in costs associated with public co mpany reporting requirements and newly
applicable corporate governance requirements .  Please also reconcile these disclosures

Ralph Montrone Trail One, Inc. May 3, 2011 Page 3

with the disclosure in the first two sentences  of the first full para graph on page 23 and the
disclosure in the last  sentence of the fifth full paragraph on page 24.
 We have a short development state operating history, page 9

12. Please revise this risk fact or to correct your reference to “December 31, 2011.”  In
addition, revise the risk factor because it appears to be incomplete or advise.
Management’s Discussion and Analysis of Fina ncial Condition and Result of Operations, page
16
 General Overview; Nature of Business, page 16

13. We note your response to our prior comment 17;  however, you continue to state that you
will provide an internet site in March 2011 fo r customers to purchase automobile license
plate tags.  Please revise your disclosure to describe the current status of your website.

14. We note your disclosure in the four bullet points on page 18.  The uses for the $75,000, if
raised, set forth in these four bullet points do not appear to match the disclosure in the
risk factor starting at the bottom of page 6.  We also note that the disclosure in the six
bullet points at the bottom of page 23 and in the four bullet points on page 27 appear
inconsistent with the above referenced disc losure on pages 6 and 18.  Please advise or
revise for consistency.
 Liquidity and Capital Resources, page 22

15. We note your response to our prior comment 15 and we still note your disclosure in the
last sentence on page 22 that you may have  to reduce expenses, including officer’s
compensation, if you are unable to achieve prof itable operations in the near term.  We
note similar disclosure in the second sentence  of the first full paragraph on page 22.
These statements appear to conflict w ith your disclosure on pages 33 and 34 which
indicate that you are not payi ng any salaries at this time and do not have any current
intention of paying any salaries.  Please  advise or revise  for consistency.
 Satisfaction of Our Cash Obligations for the Next Twelve Months, page 24

16. We note your disclosure regarding the devel opment of the necessary software for the
CNC machine and programming of the CNC machine.  Please revise to disclose who will
perform these functions, their costs and estimated time to co mplete these tasks.  If
applicable, please also revise your Plan of Operation secti on to include these tasks and
the timeframes for their completion.

Ralph Montrone Trail One, Inc. May 3, 2011 Page 4

Plan of Operation, page 25

17. We note your response to our prior comment 20 and reissue our comment.  Please revise
your Plan of Operation section to include the description of your business plan that
currently appears in the Description of Busi ness section on page 27.  In addition, please
describe your plan of operation in more deta il here and in the Management’s Discussion
and Analysis of Financial Condition and Resu lts of Operations s ection.  For example,
please revise to indicate when you plan to begin producing the tags.  In doing this,
discuss each specific step you intend to take to begin producing the tags and your
intended sources and uses of funds.  Provide timeframes and quantified estimates of these
amounts for each step in producing the tags  and discuss what marketing methods you
intend to focus on.  Also indicate what your pr iorities in the use of funds are if you do not
obtain the full amount required to finance your operations.
 Description of Business, page 26

 Employees, page 31

18. We note your response to our prior comment  25 and your plans to begin paying Mr.
Montrone’s salary when you raise $75,000 in  funding.  However, on page 33 you state
that you will not pay any compensation until your operations generate sufficient cash
flow.  Please revise for c onsistency or advise.
 Management, page 31

 Directors, Executive Officers, Promoters and Control Persons, page 31

19. Please provide the information in the table in this section as of a more recent date than
September 9, 2010.
 Part II

 Item 13.  Other Expenses of Issuance and Distribution, page II-1

20. We note your responses to our prior comments  2 and 11.  Please update this section as
appropriate.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Ralph Montrone Trail One, Inc. May 3, 2011 Page 5

Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

 You may contact Patrick Kuhn at (202) 551-3308 or Lynwood Shenk at (202) 551-3380
if you have questions regarding comments on the financial statements and related matters.
Please contact Tonya Bryan at (202) 551- 3601 or me at (202) 551-3574 with any other
questions.
Sincerely,

Julie F. Rizzo Attorney-Advisor
  cc (via fax): Steven Sager   (877) 255-9218